Public administration reform • 10. 07. 2025.

Records of the Real Estate Administration on service contracts “against” the Real Estate Administration

With the protection of personal data, we are publishing in full the records of service contracts in the Real Estate Administration, in order to prevent misinterpretation of our research work. We thank the management of this institution for their unfounded denial, which has brought us new insights, even less favorable to the practice of using service contracts in the Real Estate Administration.

Following the response of the Real Estate Administration to the data of Institute Alternative, published in Pobjeda under the headline “The claim about the continuous engagement of one person for 13 years on a service contract is false”, we are publishing the complete records that the Administration itself submitted to us. These records clearly show the duration of engagements in this institution based on service contracts, with appropriate data protection.

We emphasize that in our analysis, as well as in the article published in Pobjeda, we never stated that it was a matter of uninterrupted engagement, but rather that the same person had been engaged for 13 years in the same institution. According to the submitted records, it is evident that, among others, one person was engaged for a total of 13 years, including two uninterrupted periods of six and seven years, which defeats the purpose of service contracts as short-term contractual engagements. This case was illustrative for us because that person’s engagement dates back to 1996.
However, we must note that after the response from the Real Estate Administration, we re-examined the submitted documentation and found that the records clearly show that one individual has been engaged since 2008. Unlike most other engagements listed, no end date was provided. The only possible interpretation of this information is that one individual has been continuously engaged for at least 16 years, that is, at least until November 2024, when we requested the records. For the same person, engaged since 2008, we also possess copies of service contracts signed in 2023 and 2024, which further strengthens the correctness of our interpretation of the submitted information. Therefore, instead of unfoundedly disputing our work, we call on the management of the Real Estate Administration to thoroughly familiarize itself with its own records.

In line with good practices in our research and advocacy work, we had previously submitted to the Real Estate Administration a draft analysis on service contracts. It is true that this institution provided comments on our draft, and we accepted those referring to the fact that the number of employees in the Real Estate Administration had not increased in proportion to the workload. Regarding the comments on the length of engagement based on service contracts, in our response to the Administration on June 9, aimed at clarifying our findings, we submitted the records of service contracts from the Real Estate Administration. We did not receive any written feedback afterwards.

The invitation from the Real Estate Administration to conduct a direct review of their work for the purpose of objective assessment, and their claim that they did not receive a response from us, we consider an inappropriate interference in our working methods. The Law on Free Access to Information (FOI) clearly prescribes the manner of accessing documentation held by public authorities, and by submitting our request we clearly opted for the methods that suit our work.

Our analysis “A System Without Control: Temporary Engagements in the State Administration of Montenegro” showed that institutions are not addressing this type of engagement, which is meant for specific and time-limited tasks but is being used to circumvent the regular employment procedure. We hope that these records, as well as the other findings and recommendations of our analysis, will contribute to a better understanding of the scope of this problem and lead to a comprehensive solution.

The records of the Real Estate Administration are available here.